FAC Explorer

Finding 50875 (2022-008)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-07-27
Audit: 53428
Organization: City of Baton Rouge - Parish of East Baton Rouge (LA)
Auditor: Postlethwaite & Netterville Apac

AI Summary

  • Core Issue: The City-Parish failed to adequately monitor subrecipients for compliance with Davis-Bacon wage requirements on construction projects.
  • Impacted Requirements: Non-compliance with monitoring obligations for subrecipients under the CDBG program.
  • Recommended Follow-Up: Establish a clear process for ensuring subrecipients effectively monitor Davis-Bacon compliance on all construction contracts.

Finding Text

2022-008) Davis Bacon Wage Requirements Questioned Costs: Undetermined Department of Housing and Urban Development 14.218 Community Development Block Grant (CDBG) Grant No(s): B-18-MC-22-0002 Criteria: Contracts and subcontracts involving construction activity with CDBG funds are subject to the Davis-Bacon prevailing wage requirements. As such, the City-Parish, as grantee, must monitor its subrecipients with construction activity to ensure that the subrecipient is monitoring the construction contractors for Davis Bacon prevailing wage requirements. Condition: The City-Parish did not sufficiently monitor its subrecipients to ensure their monitoring of contractors? compliance with Davis Bacon wage requirements. Universe/ Population: Two construction projects occurred in 2022 that were carried out through subrecipients. One of the two subrecipients was not monitored to ensure compliance with their Davis Bacon responsibilities. Effect: The City-Parish is non-compliant with the requirements to monitor its subrecipients with respect to Davis-Bacon compliance. Cause: The administration of the City-Parish?s CDBG Program was in transition during 2022. Recommendation: The City-Parish should develop a process to ensure its subrecipients are monitoring Davis Bacon compliance on their construction contracts. View of Responsible Official: All OCD contracts with developers include requirements to comply with Davis-Bacon. As part of the approved policies and procedures, the OCD requests evidence of Davis-Bacon compliance during the closeout of the project in order to ensure complete records. The OCD withholds the retainage at the end of the project until those records are received and reviewed as part of project close-out. The project cited for a lack of Davis-Bacon monitoring began the close-out process just as the audit was being finalized in June 2023 and per the OCD policy, the final reimbursement to the developer is being held until complete Davis Bacon records are submitted, reviewed, and approved. To implement best practices moving forward, the OCD is reviewing the policies and procedures and identifying ways to improve the collection and review of Davis-Bacon compliance. The current staff is scheduled to participate in training and is developing new reporting requirements in alignment with that training.

Corrective Action Plan

2022-008) David Bacon Wage Requirements Management?s response and corrective action is as follows: All OCD contracts with developers include requirements to comply with Davis-Bacon. As part of the approved policies and procedures, the OCD requests evidence of Davis-Bacon compliance during the closeout of the project in order to ensure complete records. The OCD withholds the retainage at the end of the project until those records are received and reviewed as part of project close-out. The project cited for a lack of Davis-Bacon monitoring began the close-out process just as the audit was being finalized in June 2023 and per the OCD policy, the final reimbursement to the developer is being held until complete Davis Bacon records are submitted, reviewed, and approved. To implement best practices moving forward, the OCD is reviewing the policies and procedures and identifying ways to improve the collection and review of Davis-Bacon compliance. The current staff is scheduled to participate in training and is developing new reporting requirements in alignment with that training. Expected Implementation Date: July 2023 Contact person: Marlee Pittman, Interim Director, Office of Community Development

Categories

Subrecipient Monitoring Cash Management Reporting

Other Findings in this Audit

  • 50873 2022-006
    Significant Deficiency Repeat
  • 50874 2022-007
    Significant Deficiency
  • 50876 2022-009
    Significant Deficiency
  • 50877 2022-006
    Significant Deficiency Repeat
  • 50878 2022-007
    Significant Deficiency
  • 50879 2022-010
    Material Weakness
  • 50880 2022-011
    Material Weakness
  • 50881 2022-012
    Material Weakness
  • 50882 2022-012
    Material Weakness
  • 50883 2022-002
    Significant Deficiency Repeat
  • 50884 2022-003
    -
  • 50954 2022-004
    Significant Deficiency
  • 50955 2022-005
    Significant Deficiency
  • 50956 2022-013
    Significant Deficiency
  • 50957 2022-014
    Significant Deficiency
  • 627315 2022-006
    Significant Deficiency Repeat
  • 627316 2022-007
    Significant Deficiency
  • 627317 2022-008
    Significant Deficiency
  • 627318 2022-009
    Significant Deficiency
  • 627319 2022-006
    Significant Deficiency Repeat
  • 627320 2022-007
    Significant Deficiency
  • 627321 2022-010
    Material Weakness
  • 627322 2022-011
    Material Weakness
  • 627323 2022-012
    Material Weakness
  • 627324 2022-012
    Material Weakness
  • 627325 2022-002
    Significant Deficiency Repeat
  • 627326 2022-003
    -
  • 627396 2022-004
    Significant Deficiency
  • 627397 2022-005
    Significant Deficiency
  • 627398 2022-013
    Significant Deficiency
  • 627399 2022-014
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $37.49M
21.023 Emergency Rental Assistance Program $25.10M
20.205 Highway Planning and Construction $6.92M
97.039 Hazard Mitigation Grant $6.14M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $5.84M
97.029 Flood Mitigation Assistance $5.47M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $4.75M
59.075 Shuttered Venue Operators Grant Program $3.52M
17.258 Wia Adult Program $1.54M
14.218 Community Development Block Grants/entitlement Grants $1.32M
17.259 Wia Adult Program $1.17M
20.106 Airport Improvement Program $1.13M
93.569 Community Services Block Grant $1.11M
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $936,096
17.278 Wia Adult Program $879,136
93.137 Community Programs to Improve Minority Health Grant Program $818,074
93.686 Ending the Hiv Epidemic: A Plan for America Ryan White Hiv/aids Program Parts A and B (b) $757,086
93.600 Head Start $678,481
14.231 Emergency Solutions Grant Program $602,607
10.558 Child and Adult Care Food Program $586,510
93.568 Low-Income Home Energy Assistance $339,173
97.067 Homeland Security Grant Program $245,647
20.600 State and Community Highway Safety $202,452
93.658 Foster Care_title IV-E $119,398
93.498 Provider Relief Fund $113,017
93.127 Emergency Medical Services for Children $101,508
95.001 High Intensity Drug Trafficking Areas Program $97,145
20.616 National Priority Safety Programs $79,996
16.034 Coronavirus Emergency Supplemental Funding Program $78,600
14.905 Lead Hazard Reduction Demonstration Grant Program $76,888
20.607 Alcohol Open Container Requirements $75,705
14.241 Housing Opportunities for Persons with Aids $67,030
97.042 Emergency Management Performance Grants $61,857
16.843 Gulf States Regional Law Enforcement Technology Training and Technical Assistance Initiative (b) $30,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $21,000
66.817 State and Tribal Response Program Grants $20,000
17.277 Wia Adult Program $14,798
16.609 Project Safe Neighborhoods $10,854
14.239 Home Investment Partnerships Program $9,810
97.024 Emergency Food and Shelter National Board Program $7,912
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $7,356
10.664 Cooperative Forestry Assistance $4,130
93.069 Public Health Emergency Preparedness $1,861
93.914 Hiv Emergency Relief Project Grants $201
97.044 Assistance to Firefighters Grant $12